IRS Lawyer

FRESH START INITIATIVE 2012- Fresh Start Initiative For offers in Compromise 1.10 On May 21, 2012 the Internal Revenue Service announced another expansion of its "Fresh Start" initiative by offering more flexible terms to its Offer in Compromise (OIC) program…

The IRS has several programs in place, including the Offshore Voluntary Disclosure Program. Even those who intentionally hid their money overseas are allowed to confess to the IRS and correct their taxes for eight years.

By Robert E. McKenzie Depriving Taxpayers of Administrative Due Process of Law Many practitioners have observed the aggressive approach that the IRS has recently taken to collect taxes from alleged nominees and alter egos of delinquent taxpayers. This summary collection approach deprives the alleged…

Below are links to the latest revisions of the national standards used in collection financial analysis. The charts show the itemized monthly national standards and the total money national standards as revised in March 2010. The new standards are effective…

On September 13th, Robert E. McKenzie participated in an IRS panel on the dissolution of business partnerships and marriages. Topics discussed: Introduction Hazards to preparer similar in business breakup and marriage breakup Circular 230 provision Divorce Change in filing status When…

"Darrell Issa, This Generation's Joe McCarthy" In my most recent blog, I discuss the comments made by Lois Lerner, head of the IRS Tax-Exempt and Government Entities Division. Ms. Lerner commented on the IRS and tax exemption status of social…

Procedural Requirements for Imposition of Penalties and Additions to Tax
The Internal Revenue Service Restructuring Act required that each notice imposing a penalty include the name of the penalty, the Code section imposing the penalty, and a computation of the penalty. The Act also requires the specific approval of IRS management to assess all non computer generated penalties unless excepted. This provision does not apply to failure to file penalties, failure to pay penalties, or to penalties for failure to pay estimated tax.

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